ML20126H036

Advises That Sealing Criteria Proposed in Unacceptable.Criteria Deviates from Guidelines for Which Adequate Technical Justification Needs to Be Provided.Listed Alternatives Should Be Considered for Resolution

ML20126H036
Person / Time
Site:	Perry
Issue date:	06/10/1985
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
References
NUDOCS 8506180223
Download: ML20126H036 (5)

Text

1. UNITED STATES

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5l NUCLEAR REGULATORY COMMISSION W ASHINGTON, D. C. 20555

%,**.+/ JUN 10 BB5 Docket No.: 50-440 Mr. Murray R. Edelman, Vice President Nuclear Operations Group The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101

Subject:

Fire Protection Barrier Penetrations Design - Perry Nuclear Power Plant, Unit 1 In the Perry Fire Protection Evaluation Report (FPER), Section 5, Pages 5-16

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and 5-19, it is stated that all penetrations to fire areas are sealed to main-tain the 3-hour fire resistance rating of the fire barriers, with penetration seal designs tested in accordance with ASTM E-119; and that cable penetrations in fire barriers are sealed consistent with the fire resistance ratings of the barriers. This statement is consistent with the NRC staff guidelines. How-ever, during the site visit made by the NRC staff in March 1985, it was observed that conduits four (4) inches or less in diameter were not sealed in accordance with what was connitted to in the FPER. (The staff's site visit report of fire protection findings and agreements was transmitted by my letter dated April 16, 1985).

In your May 3,1985 letter (PY-CEI/NRR-0234L) a solution to this matter is proposed utilizing sealing criteria for conduit 4 inches or less in diameter that are considered to be deviations to the staff's Branch Technical Position CMEB 9.5-1 Section C.5.a(guidelines delineated 3). The solutions proposed in would allow unsealed conduits and conduits sealed only at one end of the barrier penetration. Additionally, the sealing criteria does not address other factors related to unsealed openings communicated to holders of Construction Permits, et.al. by NRC Generic Letter 85-01 dated January 9,1985. (Specific reference is made to Enclosure 6, Question 8.8 " Smallest Openings in a Fire Barrier" of thatgenericletter). Unsealed conduits or conduits sealed only at one end of a fire barrier that separates redundant safe shutdown divisions should not permit flame, radiant energy, smoke or hot gases to pass through the barrier and cause damage to redundant shutdown divisions on the other side of the barrier.

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. . 35116 Sh Mr. Murray R. Edelman It is therefore requested that your staff assess the adequacy of existing fire protection and establish sealing criteria predicated on fire test results and fire hazards analyses. Should your staff's assessment necessitate requesting further deviation to the NRC guidelines and Branch Technical positions they should address the quantity and nature of combustible materials, and the fire fire hazards on both sides of the barrier including: exterior walls; locations of wall openings in relation to the ceiling; location, vulnerability and import-ance of shutdown systems on both sides of the barrier; and the compensating fire protection.

In sumary, the staff considers the sealing criteria proposed in your May 3,1985 letter to be unacceptable in that it constitutes a deviation to the staff's guide-lines for which adequate technical justification needs to be provided. It is suggested that the following alternatives be considered for resolving this particular matter:

(1) Seal the conduits in question in accordance with Branch Technical Position CMEB 9.5-1, Section C.S.a(3);

(2) Provide test data for other sealing configurations that demonstrate

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that their fire rating is equivalent to the barrier in which they are installed; or (3) Identify and justify the unsealed conduit penetrations considering all relevant factors.

This item and others delineated in the staff's site visit report are considered outstanding open issues which must be resolved by correcting the deficiencies and/or obtaining the staff's acceptance to deviations from its guidelines prior to Perry Unit I licensing. Should this item or the others addressed in the staff's report not be settled before the next Perry SER supplement is published, they will be documented in that supplement as new outstanding issues. There-fore, it is urged that settlement of all fire protection related matters ident-ified from the staff's March 1985 fire protection audit be given priority attention. Should there be any questions, or if your staff wishes to discuss this letter with the NRR staff, please advise the Perry Project Manager, John J. Stefano, accordingly.

Sincerely, B. J. Youngblood, Chief Licensing Branch No. I Division of Licensing DISTRIBUTION See attached page 7

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Murray R. Edelman It is therefore requested that your staff assess the adequacy of existing fire protection and establish sealing criteria predicated on fire test results and and fire hazards analyses. Should your staff's assessment necessitate requesting further deviation to the NRC guidelines and Branch Technical positions they should address the quantity and nature of combustible materials, and the fire hazards on both sides of the barrier including: exterior walls; locations of wall openings in relation to the ceiling; location, vulnerability and import-ance of shutdown systems on both sides of the barrier; and the compensating fire protection.

In summary, the staff considers the sealing criteria proposed in your May 3,1985 letter to be unacceptable in that it constitutes a deviation to the staff's guide-lines for which adequate technical justification needs to be provided. It is suggested that the following alternatives be considered for resolving this particular matter:

(1) Seal the conduits in question in accordance with Branch Technical Position CMEB 9.5-1, Section C.S.a(3);

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(2) Provide test data for other sealing configurations that demonstrate that their fire rating is equivalent to the barrier in which they are installed; or (3) Identify and justify the unsealed conduit penetrations considering all relevant factors.

This item and others delineated in the staff's site visit report are considered outstanding ope.n issues which must be resolved by correcting the deficiencies and/or obtaining the staff's acceptance to deviations from its guidelines prior to Perry Unit I licensing. Should this item or the others addressed in the staff's report not be settled before the next Perry SER supplement is published, they will be documented in that supplement as new outstanding issues. There-fore, it is urged that settlement of all fire protection related matters ident-ified from the staff's March 1985 fire protection audit be given priority attention. Should there be any questions, or if your staff wishes to discuss this letter with the NRR staff, please advise the Perry Project Manager, John J. Stefano, accordingly.

Sinc el ,

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. j. Y ungblo d, Chief Lic' ens ng Branch No. 1 Division of Licensing

- o JUN 10 265 Mr. Murray R. Edelman Perry Nuclear Power Plant The Cleveland Electric Units 1 and 2 Illuminating Company CC*

Jay Silberg, Esq. Mr. Larry 0. Beck Shaw, Pittman, & Trowbridge The Cleveland Electric 1800 M Street, N. W. Illuminating Company Washington, D. C. 20006 P. O. Box 97 E-210 Perry, Ohio 44081 Donald H. Hauser, Esq.

The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 Resident Inspector's Office U. S. Nuclear Regulatory Commission -

Parmly at Center Road Perry, Ohio 44081 Regional Administrator, Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Donald T. Ezzone, Esq.

Assistant Prosecuting Attorney 105 Main Street Lake County Administration Center Painesville, Ohio 44077 Ms. Sue Hiatt OCRE Interim Representative 8275 Munson Mentor Ohio 44060 Terry J. Lodge, Esq.

618 N. Michigan Street Suite 105 Toledo, Ohio 43624 John G. Cardinal. Esq.

Prosecuting Attorney Ashtabula County Courthouse Jefferson, Ohio 44047

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